ERG 338: Medical Support

1. ERG 338: Medical Support An Overview…what has stayed the same with medical support but needs reiterating and what’s new

2. ERG 338: What Stayed the Same? • Medical Support includes health coverage provided for a child or children in a IV-D case in which there is a medical support order. This includes: (1) private health insurance; (2) publicly-funded health insurance, if a parent is ordered by a court or administrative process to provide cash medical support payments to help pay the cost of Medicaid or State Child Health Insurance Program (SCHIP); (3) cash medical support, including payment of health insurance premiums; and (4) payment of medical bills (including dental or eye care). Indian Health Service and Tricare are acceptable forms of medical support. Medical support may be provided by either the custodial parent, non-custodial parent or any other person, such as a step-parent

3. ERG 338: What Stayed the Same? • Health insurance a subset of medical support, which is defined as private health insurance, publicly-funded health insurance, if a parent is ordered by a court or administrative process to provide cash medical support payments to help pay the cost of Medicaid or State Child Health Insurance Program (SCHIP), or military health insurance. Health insurance includes fee for service, health maintenance organization, preferred provider organization, and other types of coverage which is available to either parent, under which medical services could be provided to the dependent child (ren).

4. ERG 338: What Stayed the Same? Cash medical support is a subset of medical support, which is an amount ordered to be paid toward the cost of health insurance provided by a public entity or by another parent through employment or otherwise, or for other medical costs not covered by insurance.

5. ERG 338: What Stayed the Same? • $TARS coding of medical cases is essential to the program. Coding effects the 157 report, incentives, audit findings and system functions. Therefore, Health Insurance and Who is Ordered to Provide must be coded correctly. • When medical support is ordered, select “yes” in the Medical Support Ordered field on the court order screen. • When health insurance is ordered, select “yes” in the Health Insurance ordered field on the Support Order Screen.

6. ERG 338: What Stayed the Same? • If the NCP is ordered to provide health insurance, the Ordered to Provide Health Insurance field would be checked as “NCP ordered”. If the CP is ordered to provide health insurance, the Ordered to Provide Health Insurance field would be checked as “CP ordered”. • Also add all,(NCP, CP or Non-Parent Caretaker) insurance data to the Insurance screen. If insurance is not through an employer, the agent must enter the insurance policy information on the insurance screen after completion of NMSN process.

7. ERG 338: What Stayed the Same? • Medical Support must be addressed anytime case is in court; Establishment, Rev/Mod, Add-a-child, Enforcement, etc. • Agent still determines reasonable cost of health insurance by applying the 5% of Gross Reasonableness Standard. • Employer still ensures that the employee’s child support and other mandatory deductions do not exceed the Consumer Credit Protection Act limits. • Contact Center Agents are responsible for all matters regarding medical support when calls received. Local office agents are responsible for all matters regarding medical support when parties visit local office.

8. ERG 338: What Stayed the Same? • If NCP is ordered to provide insurance coverage but CP is already maintaining insurance coverage for the child(ren), there is no requirement for the non-custodial parent (NCP) to provide additional coverage. However, the NMSN is still required. • If the NCP is not required to provide coverage, document the reason on the case action log. Advise him/her that should the CP involuntarily lose health insurance coverage for the child(ren), DCSS will review the case to make a new reasonableness determination. If insurance is reasonable at that time, DCSS will issue a NMSN and notify them.

9. ERG 338: What Stayed the Same? • The NMSN is used by the employer to respond regarding the NCP’s eligibility for and to enroll the child in the plan. The NMSN is made up of two parts: Part A which contains Notice to Withhold for Health Care Coverage, instructions for completion and the Employer Response Sheet. Part B contains the Notice to the Plan Administrator, which serves as a Qualified Medical Child Support Order requiring the child/ren named to be enrolled in health coverage as well as the Plan Administrator’s Response Form. • The employer is instructed to complete and return Part A or Part B,as applicable, to NMSN vendor. • If the vendor has an issue processing the NMSN, agent will receive an escalation.

10. ERG 338: What Stayed the Same? • Part A, which must be completed and returned within 20 business days, is used by the employer to respond when insurance is not available: • NCP was never employed by the employer, • NCP was terminated by the employer, • Employer does not offer dependent or family health care coverage to employees, • NCP is not eligible for family health coverage, or • Cost of insurance is not reasonable or exceeds the C.C.P.A. limitations • If Part A of the NMSN is returned, the vendor will document information on the NMSN in the Case Action Log. • Part B, which must be completed and returned within 40 days, is used by the employer when coverage is availableand is forwarded by the employer to the Plan Administrator who manages the health plan. • The Plan Administrator will do the following: • Determine whether to enroll the child in the plan, • Notify NMSN vendor that there are multiple options available and the CP must select the option, • Notify NMSN vendor that there is a waiting period before the insurance is in effect for the child, enroll the child after the waiting period expires, or • Notify NMSN vendor with reasons that the order is not a “qualified medical child support order”, and • Complete Part B, which reports which of the above actions, was taken. • If Part B of the NMSN is returned, the vendor will update the insurance information

11. ERG 338: What Stayed the Same? • The NMSN vendor will also provide follow up on pending NMSN requests any time the NMSN is touched by vendor but specifically as outlined: • 50 days via a letter to employer, • 60 days via a telephone call to employer, • 75 days via a letter to employer. At the 75 day mark (from the date of export), NMSN vendor will send a final letter to the employer as well as notify DCSS of the employer’s apparent willful intent to fail to comply with reporting requirements through nightly export. • All actions will be updated on Employer Screen on $TARS and CAL. See ERG for a list of pending codes. • The process for hearings and/or if NCP disputes coverage remains the same.

12. ERG 338: What Stayed the Same? Under No circumstances, should the vendor or agent recommend a specific insurance plan to the CP. • You may provide the following questions to assist the CP in choosing coverage: • Is coverage available? (i.e. is a doctor or facility is within fifty miles of the child) even across state lines, coverage may be considered available and acceptable. • What are the deductibles and co‑payments? • What coverage is offered and are the children’s primary physicians in the plan?

13. ERG 338: What Stayed the Same? • If the child is enrolled in a health insurance plan, the Plan Administrator will furnish the CP with the insurance cards and coverage information. • If NMSN vendor or the local DCSS receives the cards and insurance coverage information from the Plan Administrator, they forward the documents to the CP and document the CAL. SSR can be used to accompany the cards. • Whenever Part A or Part B is returned, NMSN vendor notifies the CP of the availability of health insurance coverage by letter. CP is not notified of pending actions.

14. ERG 338: What Stayed the Same? • Special Case Scenarios: • Enforcing Medical Support on Cases Involving the Social Security Administration (SSA): When updating the NCP employer screen with Social Security Administration due to NCP receiving or having a pending claim for either RSDI or SSI, the NMSN radio button should not be checked to be auto generated. Per ERG Procedure 275, there should not be an occasion that the NMSN should be sent to the SSA (unless the ordered party is employed by SSA). However, there may be income or lump sum payments that may be subject to FIW income withholding. • Enforcing Medical Support Only Cases (NA/MI): On cases coded as medical support only or NA/MI, the NMSN will generate in the same fashion as other appropriately coded cases. • Enforcing Medical Support on Arrears Only Cases: $TARS will screen the criteria for case sub-type (NA/FR) as well as active/current account before generating a NMSN. If the case doesn’t pass these export edits, meaning that it is coded NA/FR and has no current support account, no NMSN will be generated by $TARS. However if the case is no longer a current support case and the children are not emancipated, medical support enforcement is still applicable. • Enforcing Medical Support on Interstate Cases: When enforcing medical support on interstate cases, there is no difference to enforcing any other DCSS case as long as the order can be determined to be a Qualified Medical Child Support Order (QMCSO). The vendor’s and agent’s role are the same . Georgia DCSS orders are written as such to constitute a QMCSO.

15. ERG 338: What’s New? • The medical checklist NMC was created to assist agents in capturing as much information as possible from all parties on the case in regards to health insurance during customer interaction. The form can be generated from DocGen, completed and maintained in the case file. • If the case is coded Family Violence, the CP address will be changed by $TARS to the local DCSS office address on any information related to the NMSN. This is a behind the scenes edit and won’t change the actual address screen. • It is important that agents enter the end date to any employment and/or insurance coverage as they become aware of change. If actual date is not known, use date the information became known.

16. ERG 338: What’s New? System Enhancements • W4 Hits: $TARS automatically moves the employer information to Sequence 1 on the NCP Employer Screen, generates an IWO and NMSN if the Medical Support is Ordered field and Health Insurance Ordered is coded “Yes”. • When the agent receives new employment information, the Employer Screen on $TARS, Sequence 1 is updated. This update will cause the FIW and NMSN message box to light up at bottom of the Employer screenIF the Health Insurance Indicator and NCP Ordered Indicator are populated.

17. ERG 338: What’s New? System Enhancements, Continued • Once the agent selects the NMSN document, $TARS will do an online check for correct coding or other issues. Agent may receive an error message on the screen at that time. • If the agent corrects the error immediately, the NMSN will go forward to the overnight batch process. At this point, $TARS is looking only at the case Agent is working in. • If the agent doesn’t correct the error(s) immediately (the same day), they will receive 1 prompt/CAL the next day regarding the error(s). • If the agent corrects the error(s) the following day or later after receiving the prompt, they must manually generate the NMSN again.

18. ERG 338: What’s New? System Enhancements, Continued • If the NCP has other cases, these cases will be reviewed and if other errors are noted during the overnight batch process, the agent will receive a prompt the following day instructing them to review CAL for details regarding errors. •  If the agent makes the corrections immediately (the same day), the NMSN will be generated automatically; the agent will not need to revisit the radio button to generate. •  If the agent doesn’t correct the error(s) immediately (the same day), they will receive 1 prompt/CAL the next day regarding the error(s).

19. ERG 338: What’s New? System Enhancements, Continued •  If they correct the errors the following day or later after receiving the prompt, they must manually generate NMSN again. The agent can check the Employer Screen to see if the Date NMSN Sent field is populated to ensure that the NMSN was sent. • Tip: Another way the agent can tell whether or not they need to generate the NMSN after making corrections is to check the Employer Screen to see if the NMSN radio button is enabled. If so, they would need to check the box to generate the NMSN.

20. ERG 338: What’s New? • Employers Not Reporting Timely: If the NMSN has not been completed and returned by the 75th day, NMSN vendor will send the employer a letter and will notify DCSS via the nightly export of the incomplete status. At the 85 day mark, $TARS will generate a prompt to the agent for follow up. Upon receipt of the prompt, Agent should attempt to contact employer by phone, whenever possible, to have employer complete and return the NMSN. If employer does respond to the NMSN during the 85-100 day window, local DCSS office should mail the completed NMSN to NMSN vendor immediately upon receipt, for data entry. Contact person and mailing address for PSI on file in DCSS office.

21. ERG 338: What’s New? • If Agent is unable to secure the completed NMSN via phone call, Agent should talk with local DCSS attorney to discuss the willful intent of the employer to not comply with NMSN. If Agent and local DCSS attorney feel that there is evidence to support willful intent, Agent should generate FormNID via DocGen. This letter should be sent certified mail to the employer. This process, to include phone call to employer and the possible mail out of FormNID, should happen within one business day of receipt of the prompt. If, after an additional 15 days (or 100 days from the date the original NMSN was sent to employer) there is still no response, Agent may discuss with local attorney whether employer qualifies as an egregious offender.

22. ERG 338: What’s New? • For this purpose, egregious is being defined as an employer that has failed to complete and return the NMSN on a case in over 100 days and/or an employer that has a 100 or more outstanding NMNS’s on different DCSS cases. The latter can be quantified via the list of non compliant employers maintained at the state office. The policy specialist at the State Office will maintain an ongoing list of employers that are not in compliance with NMSN reporting guidelines as reported by NMNS vendor. This list will be maintained on a quarterly basis and can be used when determining the egregious nature of the willful intent of a non compliant employer. • Once the Agent and local attorney have made the determination as to the egregious nature of the non compliance, a decision should be made as to whether employer should be scheduled for court to address employer’s willful intent to fail to comply with reporting requirements. (O.C.G.A. §19-11-26-29) • This process will be completed initially at the State Office level.

23. ERG 338: What’s New? • Reporting: A weekly report will be generated via E-Bill showing cases where the “Status returned to DCSS” date is blank and “Sent to Vendor” is older than 85 days. The report is SIDR29PR and supervisors and agents can manage the need for possible legal action against employers using this report. Cases on this report will only appear once, meaning that once the 85th day has been reached, the case will appear on that week’s report but will fall off before the following week’s report is generated. This report cannot be used as a historical document unless the report is printed or is downloaded to Excel.

24. ERG 338: What’s New? • Reporting: A monthly report will be generated by office showing status of all NMSNs sent in that month and/or pending from previous months. Cases do not come off this report until the NMSN has been completed. The following month, all completed NMSNs fall off. The report is SIDE39PR and supervisors and agents can use this as a case management tool. This report gives a snapshot of the time frame of outstanding NMSNs.

25. Policy Studies, Inc. Address and Phone: Customer Service Contact Number: (866) 304-8199 Address to Completed NMSNs to be mailed: Policy Studies, Inc. Attention: Alexandria Walker P.O. Box 2584 Atlanta, Georgia 30301